Eastern Associated Coal Corp. v. United Mine Workers of America, District 17

Summary

The Court, in an opinion by Justice Breyer joined by Chief Justice Rehnquist and Justices Stevens, O'Connor, Kennedy, Souter, and Ginsburg, held that public policy did not bar enforcement of an arbitration award conditionally reinstating a truck driver who twice tested positive for marijuana. The governing statute and regulations favored both transportation safety and rehabilitation, did not mandate discharge, and left disciplinary decisions to labor-management negotiation. The Court also stated that the public-policy exception is not confined to awards that themselves violate positive law, although the exception remains narrow. Justice Scalia, joined by Justice Thomas, concurred in the judgment, agreeing that reinstatement was permissible but rejecting the majority's endorsement of authority to invalidate otherwise lawful agreements on public-policy grounds.